Facts
- Two Federal Employers’ Liability Act (FELA) suits were filed in Montana state court against BNSF Railway Company by non-Montana plaintiffs for injuries that occurred outside Montana.
- Robert Nelson (North Dakota resident) alleged knee injuries from his railroad work; the injury did not occur in Montana.
- Kelli Tyrrell, as special administrator for the Estate of Brent T. Tyrrell (South Dakota resident), alleged workplace exposure to carcinogens caused fatal cancer; the exposure and injury did not occur in Montana.
- BNSF is incorporated in Delaware and has its principal place of business in Texas.
- In Montana, BNSF employed less than 5% of its workforce and maintained about 6% of its track mileage.
Issues
- Whether FELA § 56 (45 U.S.C. § 56) authorizes state courts to exercise personal jurisdiction over a railroad solely because it is “doing business” in the forum state.
- Whether the Fourteenth Amendment Due Process Clause permits Montana courts to exercise general personal jurisdiction over BNSF for out-of-state claims when BNSF is neither incorporated nor headquartered in Montana.
Decision
- The Supreme Court reversed the Montana Supreme Court and remanded.
- FELA § 56 was held not to expand state-court personal jurisdiction; it addresses federal venue and recognizes concurrent subject-matter jurisdiction.
- Montana lacked general personal jurisdiction over BNSF because BNSF was not “at home” in Montana under the standard articulated in Daimler AG v. Bauman.
- Justice Sotomayor concurred that § 56 does not confer personal jurisdiction but dissented from the Court’s due process analysis, concluding BNSF’s Montana operations were sufficient for general jurisdiction.
Legal Principles
- A federal statute’s venue and concurrent-jurisdiction language does not, without more, confer or expand state-court personal jurisdiction over a defendant.
- General (all-purpose) personal jurisdiction over a corporation ordinarily exists only in the state of incorporation and the principal place of business.
- Significant in-state operations, standing alone, do not establish general jurisdiction unless the case is exceptional and the corporation’s forum affiliations render it essentially “at home.”
- Daimler’s due process limits apply to all state-court assertions of general jurisdiction over nonresident corporate defendants, including in FELA actions.
Conclusion
Montana courts could not exercise general personal jurisdiction over BNSF for claims unrelated to Montana because FELA § 56 does not grant state-court personal jurisdiction and BNSF’s Montana contacts did not render it “at home” there under the Due Process Clause.